On behalf of the PVD (Prepaid Verband Deutschland) we suggest to extend the list of exemptions for payments which are excluded from the scope of the strong customer authentication explicitly for payments with anonymous payment instruments which are based on e-money. According the EU Directive 2015/849/EU (4th AML-Directive) Article 12 and 15 certain low-risk e-money based payment instruments can be issued with a simplified customer due diligence. These prepaid instruments could be rechargeable or non-rechargeable. If these instruments are issued legally without customer identification and verification it is technical impossible to fulfill the required strong customer authentication. The ECB already stressed this exemption in its Assessment Guide for Security of Internet Payments of February 2014 (page 6).